Privacy Notice for Brightside’s Online Mentoring Platform
This Privacy Notice was last updated on 31 March 2022.
Brightside (which refers to ‘The Brightside Trust’) is committed to protecting and respecting your privacy. This Privacy Notice relates to your personal information, which is any information or combination of information that could be used to identify you as an individual. This Privacy Notice explains how we collect, store and use the information you provide to us or that we otherwise collect about you – this may include some information that we have already collected when you first have the opportunity to read this Privacy Notice.
This Privacy Notice applies to your access and use of Brightside’s charity website, our Bright Knowledge website and Brightside’s online mentoring platform websites and app (the “Brightside Services“) and forms part of our Terms and Conditions. As a mentee, mentor or coordinator using Brightside’s online mentoring platform, when you register your online mentoring account, you will be asked to acknowledge that you have read and understood this Privacy Notice. In this Privacy Notice we refer to users of the Brightside Services as “service users“.
We may update or change this Privacy Notice so please check this page from time to time and review this statement for changes. We will notify you of changes to this Privacy Notice by posting an information banner on our home page for a reasonable period of time and changing the “last updated” date at the top of this notice – in the case of significant changes, we may also contact you directly to draw your attention to the changes.
If you have any questions or concerns relating to this Privacy Notice, please contact us. You can find details on specific areas of our Privacy Notice by clicking on the links below:
- Why we collect information
- What kind of information we collect
- How we use your personal information
- How we may share and disclose your information
- How we keep your information safe
- How long we keep your information for
- Third party sites
- Children’s online privacy
- Your data protection rights
- How to contact us
1. Why we collect information
We abide by applicable data protection law in our collection, use and processing of your personal information. We can lawfully process your personal information as described in this Privacy Notice because we need to do so in order to pursue our legitimate interests, and those of our Contracted Partners, for the purposes disclosed to you in this Privacy Notice, the Brightside Services agreement or within the services themselves. However, note the following points:
- we will only contact you about services in which you have expressed an interest, signed up to, or other goods, services or features Brightside and/or the Contracted Partners believe that you will find interesting
- our collection, use and other processing of information relating to health, and other personal information in the particularly sensitive categories discussed below (What kind of information we collect) is permitted on the special legal basis that it is necessary for the provision of the Brightside Services, which are confidential mentoring via our moderated messaging platform, advice or support services between your mentor, Brightside and Contracted Partner(s); and
- we may occasionally be required by law to disclose or otherwise process personal information.
2. What kind of information we collect
When you use the Brightside Services, to make your visit productive and enjoyable, and to enable Brightside to provide you with the best possible services, Brightside may collect and process certain information (including personal information) that either:
- you provide to us, for example when registering for or using our online mentoring platform, to receive our newsletter or completing an online survey
- is transferred to us from the Contracted Partner(s) including, if you use our online mentoring platform, your online coordinator (being an individual holding a Disclosure and Barring Service (“DBS”) enhanced clearance, who is authorised by Brightside and/or its Contracted Partners to implement and maintain an online mentoring programme)
- you, your mentor or mentee upload or post to the Brightside online mentoring platform during your (or their ) use of the Brightside Services (including any online survey, questionnaire or form in which you may participate); or
- you, your mentor or mentee provide to us in any other way, for example by emailing us, disclosing to us by telephone or during any meeting you may have with us, your online mentor coordinator or our Contracted Partners
This information may include the following:
- personal contact details, including your name, postcode, mobile telephone number and e-mail address;
- biographical details, including information about your employment or education and DBS/CRB checks where applicable;
- demographic information, including information in relation to your age, gender, interests and hobbies;
- sensitive information, such as ethnicity;
- statistical information, relating to your use of the Brightside Services, including course progression, messages sent and received, and number of visits to the Brightside Services,
If you are a mentor or mentee it will also include a wide range of information posted or uploaded to our mentoring platform during your and your mentoring partner’s use of the Brightside Services. This may on occasion include some limited personal information categorised as sensitive by data protection law that you or and your mentoring partner have included in conversations and/or comments posted to the platform – for example, information as to physical or mental health, religious or similar beliefs, political opinions, racial or ethnic origin or criminal convictions. Uploading or posting information in these categories is entirely voluntary. We do not use this information except in the provision of the Brightside Services to you.
If you do not provide the (non-sensitive) information that we request from you, we may not be able to allow you to continue to participate in our mentoring programmes.
We may also collect certain types of information automatically, including:
- your Internet Protocol (IP) address or device identifier
- your device’s operating system and browser type
- details of the websites visited before or after you visit our website
- pages viewed and activities undertaken whilst using the Brightside Services
3. How we use your information
Brightside may use your information for the purposes described in this Privacy Notice or as otherwise disclosed to you in the Brightside Services agreement or within the services themselves. For example, we may use your information:
- to set up a service user account so you can use the Brightside Services;
- so we can carry out the Brightside Services for you and our Contracted Partners, including:
- for our day to day operations;
- to meet our objectives as a charitable organisation; and
- to comply with legal obligations;
- to communicate with you about your use of the Brightside Services, including by way of survey where applicable;
- so we can better tailor our services to you and our Contracted Partners – Brightside will always anonymise any information used for these purposes to protect your identity;
- monitoring, evaluation, research and reporting purposes in respect of the Brightside services – except as discussed below (How we may share and disclose your information). Brightside will always anonymise any information used for these purposes to protect your identity; and
- marketing purposes in respect of the Brightside services, services in which you have expressed an interest and, also, other goods, services and features Brightside and/or the Contracted Partners believe that you will find interesting. Each time you are contacted, you will be told what you need to do or whom you need to inform if you do not want to be contacted again by that person.
4. How we may share and disclose your information
Your privacy is very important to us. We will not share your personal information with anyone outside of Brightside, other than with any Contracted Partner relevant to your mentoring programme, any online coordinator relevant to your use of the Brightside Services and our service providers (so we can provide the Brightside Services to you), except in the very limited circumstances discussed below. The platform does also allow you to share personal information with your mentor/mentee and/or groups of mentors/mentees within your mentoring programme.
Some of our third party suppliers and service providers may host personal information outside the European Economic Area (“EEA”). All of our suppliers are GDPR compliant and for each supplier we have confidentiality agreements in place and rely on the use of the European Commission’s Standard Contractual Clauses (“SCCs”), which the Court of Justice of the European Union (“CJEU”) validated on July 16, 2020 as a legal mechanism for the transfer of EU personal data.
We also keep track of the educational progress of mentees after they have completed mentoring programmes, so that we can assess the effectiveness of our services and improve them for future beneficiaries. In order to keep track of your educational progress, if you are a mentee, we may provide basic information about you (sufficient to allow you to be identified) to evaluation, research and other educational partners so that they can disclose information about your progress to us or otherwise assist us with monitoring and assessing your progress. We do not use these results in any way that might affect you individually, but only as part of our assessment of our mentoring programmes. If you do not wish us to use and share your information in this way please let us know (see Contact us).
In exceptional circumstances where a mentee or mentor is deemed to be at risk of significant harm or to have suffered significant harm, or to be a danger to another person, mentoring confidentiality may need to be broken. The mentee or mentor will be informed of our intended action, or in exceptional circumstances the action may already have been taken before the mentee or mentor can be informed. In addition, Brightside reserves the right to use or disclose any personal information as needed to satisfy any law, regulation or legal request, to protect the integrity of the Brightside Services, to fulfil your requests, or to cooperate in any law enforcement investigation.
5. How we keep your information safe
Your personal information will be kept on secure servers and kept confidential by Brightside and, except in the limited circumstances discussed above, will only be seen by Brightside staff and, if you are a mentor or mentee, our Contracted Partners and suppliers relevant to your mentoring and your online mentoring coordinator. These parties are all contractually obliged to keep your personal information secure and confidential.
From time to time, if you are a mentor or mentee, Brightside staff and your online mentoring coordinator may review messages and other materials posted or uploaded to the platform to protect your safety by ensuring that there is no misuse of the Brightside Services or of your mentoring relationship. Brightside and/or our Contract Partner(s) may occasionally use statements or comments made by individuals to evidence the impact of our mentoring programmes and/or for marketing purposes. We will always fully anonymise any statements or comments used in this way.
6. How long we keep your personal information for
Every year, at the beginning of the next academic year, we will delete, in bulk, all personal identifying information for registered users that is 6 years old based on the registration date of each user account, except if the user has been actively using the platform within the last 12 months. The data deletion process is permanent and cannot be reversed.
Any personal identifying information associated with invitations to join the mentoring platform, that are not taken up by the invitation recipient, are deleted when the mentoring programme comes to an end.
Brightside uses HEAT (Higher Education Access Tracker) to help understand the impact our mentoring programmes have on the education trajectory of our beneficiaries and how this may affect longer-term social mobility in the UK. HEAT is a secure shared database used by many UK educational institutions to identify which outreach or widening participation activities are the most effective in preparing students for Higher Education and progressing on to employment.
Each year we upload mentee data (including personal data that is sufficient enough to allow you to be identified) to HEAT, together with some limited engagement metrics from the mentoring programme you participated in. After a year, HEAT will generate a statistical report of the number of our beneficiaries that progressed on to HE. We use this report as well as our own evaluations to evidence the impact of our mentoring intervention in contributing to better outcomes for young people.
HEAT will typically retain personal data uploaded to it for 15 years after a mentee graduates or when they reach 30 years of age (whichever comes first), after which time all personal data will be permanently deleted. Further information on HEAT’s Data Retention Policy can be found here: https://heat.ac.uk/data-privacy-participants/
As part of our GDPR obligations, upon request, we will delete your personal information from our systems within 1 month.
This retention policy will be reviewed each year to ensure it remains fit for purpose and compliant with relevant legislation.
Cookies are small text files that are placed on your computer by the websites that you visit. There are two kinds of cookies: session cookies, which we use to store information relating to your current session on the site but which are deleted when you leave the site; and permanent cookies, which remain on your computer so that our site recognises you when you return.
The information in a cookie may include an encrypted version of your username and a unique identifier for that session. You need to enable cookies on your web browser in order to use this site. We also use Google Analytics to provide us with statistical data on how people use this site. Google Analytics cookies are third party cookies set by Google, which include both session and persistent cookies.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
8. Third party sites
This Privacy Notice only relates to the Brightside Services and does not extend to your use of the internet outside this website; in particular, it does not relate to any websites to which you may link to using the hypertext connections within the Project Resources section (or any other section) of our website or the Brightside Services and Brightside is not responsible for the privacy practices of other websites.
You are encouraged to read the privacy statements of the other websites you visit from your use of the Brightside Services so you are aware of their data privacy practices.
9. Children's online privacy
Brightside recognises the importance of protecting the privacy of children. We will not knowingly collect any personal information from children under the age of eleven years. When a service user discloses personal information to us, the service user is representing to us that he or she is at least eleven years old.
10. Your data protection rights
The GDPR gives individuals eight data subject rights, which are listed and explained below:
- Right to be informed: We will tell you through our Privacy Notice what data we collect about you and your use of the Brightside services, how this data is being used, how long it will be kept and whether it will be shared with any third parties.
- Right of access: You have the right to request a copy of the information that we hold about you. A Subject Access Request will typically take between 1 and 3 months to complete depending on the add-on features enabled in your mentoring programme.
- Right of rectification: You have the right to correct data that is inaccurate or incomplete. You can do this yourself by logging into your profile page on the mentoring platform and updating the details you registered with or you can ask us to do this for you by emailing firstname.lastname@example.org
- Right to be forgotten: You can ask us to erase your personal data from the mentoring platform. This is a permanent and irreversible process and means you will lose all access to your mentor/mentee and any mentoring conversations and resources you may have shared. Permanent deletion requests will be processed within one month of the request being received. We will explain the process to you and ask you to confirm you are happy to proceed before taking any action.
- Right of portability: You can request that we transfer the personal data that we hold on you to another organisation. You can ask us to do this by emailing email@example.com
- Right to restrict processing: You can request that we limit the way we use your personal data so that we keep it but only make very limited use of it.
- Right to object: You have the right to challenge certain types of processing as explained in this Privacy Notice. You can contact us about this by emailing firstname.lastname@example.org
- Rights related to automated decision-making including profiling: We do not use automated decision making or profiling on any of the Brightside services. All of these rights are subject to various exceptions and conditions. If you would like a copy of all or some of your personal information, or to exercise one of your other rights, please Contact us.
You can read more about your rights under GDPR and if you are not happy about the way we have dealt with your request you can complain to the office of the UK Information Commissioner: www.ico.org.uk.
11. Contact Us
If you have any questions or comments about this Privacy Notice or Brightside’s personal data processing or data protection practices, or wish to:
- opt out of receiving communications about services in which you have expressed an interest, or other goods, services or features Brightside and/or the Contracted Partners believe that you will find interesting;
- ask us not to disclose information about you to evaluation, research and other educational partners so that we can track your academic progress (see How we may share and disclose your information); or
- exercise the data protection rights discussed above,
Please contact us at email@example.com. You should also use this email address to let us know if any of your personal data changes. Alternatively, you can write to us at the address set out below, or call us on 0203 096 8120.
Brightside CAN Mezzanine 7 – 14 Great Dover Street London SE1 4YR